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The Importance of Using Accountable Language
by Phyllis B. Frank and Barry Goldstein
This article was conceived because of the frequency with which leaders of our movement and presenters at conferences use unaccountable language in our presentations and proposals, even as they deeply care about ending men’s violence against women and have devoted their lives to helping women partnered with abusive men.
Like all tools of oppression, unaccountable language is conditioned into our psyches, taught and learned as appropriate vocabulary and in socially acceptable sentence structure. Thus, unaccountable language is part of everyday parlance of people acting in complete good faith in trying to end men’s violence against women. We know this is true because as long as we have trained to avoid unaccountable language, we still sometimes make this error, as well. The movement to end domestic violence has not yet made the use of accountable language a priority. We hope this article will encourage all of us in the movement to do so. This is one program we can afford even in tight economic times.
Defining unaccountable language
Unaccountable language refers to the powerful messages embedded in all forms of speech and media that have all of us lapse into sentence structure that obscures perpetrators, minimizes their abuse, and supports blaming victims. One common example is the phrase “an abusive relationship.” The relationship did not hit the woman, but rather it was the abuser, typically a man who is husband or intimate partner, who was abusive. Such statements make the person who committed the offense, invisible. More specifically it is the use of passive language that results in making the perpetrator invisible. For example, a phrase like a woman was raped should be replaced by, “A man raped a woman.” The rape did not just happen, but rather the rapist committed a brutal act. The idea is to focus attention on the person responsible. Accountably speaking we might say a woman was in a relationship with an abuser or he is abusive to his intimate partner. Another example is exposed by the question, “How many women will be raped or assaulted in this year?” Do we ever hear, “How many men will rape or assault this year?”
Other examples of the language of accountability
Once, when discussing accountable language during a staff training, we looked up on the wall to see a bumper sticker that said, “Every 15 seconds a woman is assaulted.” Our objection at the time was not with the accuracy of the information but that the statement failed to focus on the cause of these assaults. “Every 15 seconds a man assaults a woman!” would be an accountable description.
During a dinner conversation, Barry, and his partner, Sharon, were discussing a series of disastrous calamities in their home caused by the builder who seemed to have deliberately sabotaged their house. After hearing about one emergency repair after another, Phyllis said it was the first time she actually understood the true meaning of an “abusive home“, since too often the phrase “abusive home” is misused to invisiblize a man who repeatedly abuses his partner in their home.
The police and media often refer to incidents in which a man brutalizes his wife or girl friend as a “domestic dispute.” This describes a man’s criminal assault as if it were some kind of mutual problem, even-sided engagement, or tame dispute, rather than an act of brutality. When a mugger assaults and robs a cab driver, it is not described as a “fare dispute.”
Unaccountable language hides responsibility
The use of accountable language is not a technicality or merely a play on words, but rather an issue with profound social consequences. The systemic use of unaccountable language minimizes men’s abuse of women, fails to take his abuse seriously, and hides his responsibility for his actions. If we say “a woman was hurt” it seems like it just happened, as if on its own accord, or by accident, and there is nothing to be done about it. If instead we refer to the man who is hurting the woman, this requires assigning responsibility and taking action to stop him from hurting her again and provide consequences for the harm he caused.
Domestic violence is comprised of a wide range of tactics used by men to maintain power and to control their intimate partners The tactics are part of a pattern of coercive actions designed to maintain, what he believes (consciously or not), are his male privileges, to control his significant other. Historically, men were assigned, by social and legal norms, control over wives and families. Today, even though that is no longer legally, and for so many, morally, the case, an “abusive relationship” or “domestic dispute” makes it seem like a communications or relationship problem between the parties. It suggests counseling or therapy as a remedy instead of consequences to hold abusers accountable for abusive, controlling, and/or violent tactics.
Social Consequences of unaccountable language
As a society our constant use of unaccountable language gives still another advantage to abusers. Unaccountable language, embedded in all dominant institutions, including the judicial system, leads police, prosecutors, defense attorneys, and judges in domestic violence custody cases to confidently assume that both parties share equal blame for not getting along. They often tell the parties they are equally responsible for the problems in the relationship and they must start to cooperate, get therapy, or anger management classes. When a mother attempts to protect her children or limit contact with an abusive father, she is routinely blamed for not getting along rather than recognized for what is a normal reaction to a partner’s abuse.
If we are going to end or at least reduce the use of unaccountable language in this society, those of us working in the battered women’s movement must take the lead and must set an example to use accountable language. Politicians often use phrases like “mistakes were made” Instead of saying, “I made a mistake.” We want society to be clear that men ,who abuse and mistreat the women they are partnered with, are responsible for their actions. We are asking presenters and others working to end domestic violence to join us in striving to use accountable language.
The vehicle through which the community-based battered women’s movement could be completely co-opted.
Hijacked by the Right is a resource for those who are or may be affected by the Family Justice Center juggernaut: survivors of domestic violence and sexual assault; advocates working in domestic violence agencies, shelters, and rape crisis centers; mainstream social service providers; churches and faith-based organizations; businesses; and concerned citizens.
The struggle for the heart of the domestic violence movement is a struggle over worldview and philosophy: whose worldview and whose philosophy will determine the perspective from which services will be provided. In Hijacked by the Right, I propose that domestic violence has become the new front of the Religious Right’s war on women. On one side is the 40-year-old Battered Women’s Movement, a community-based social justice model. On the other is the 10-year-old Family Justice Center movement, a socially and politically conservative systems-based model. Is the Family Justice Center (FJC) model — which co-locates police, prosecutors, domestic violence advocates, chaplains, child protective services, job training programs, and other community services in the same location — an evolution of the Battered Women’s Movement or its hijacking? What could possibly go wrong when law enforcement enters into partnership with the other institutional powers: government, corporations, religion, family? Consider this:
Law Enforcement: Victims tell advocates that they don’t go to the police because they fear the police and are terrified of becoming trapped withn the the criminal justice system juggernaut. Advocates fear that if they alienate the police or prosecutors, battered women will ultimately suffer the backlash.
Government: George W. Bush established the Office of Faith-Based and Community Initiatives to “save a family in jeopardy—one soul, one heart at a time.” The subsequent Family Justice Center Initiative was to provide “comprehensive services at one location, including medical care, counseling, law enforcement assistance, social services, employment assistance, housing assistance, and faith-based counseling programs.” Community-based feminist advocates are forced to collaborate with the very systems they historically monitored and held accountable.
Corporations: Privatization redirects funds from existing community-based domestic violence agencies and shelters to investor-operated businesses, opening a huge market for corporations to provide survivor counseling, risk assessment, security services, law enforcement, correctional facilities, batterers’ counseling, spiritual counseling, crisis pregnancy counseling, addictions programs, job training, housing, child care, parenting classes, budgeting… the list is virtually endless.
Religion: Most if not all FJCs engage faith-based organizations to provide services. Including faith-based providers appears to be good, but many (if not most) of them are conservative Christian organizations. Conservative Christian ideology sees men as “servant leaders” with a sacred obligation to lead their wives and children, sometimes with force. These ‘benevolent batterers’ exercise power and control over their families verbally, emotionally, psychologically, sexually, financially, and legally.
Advocacy: The Battered Women’s Movement helped women to see and reveal the abuse they suffered at the hands of men who claimed to love, serve, and protect them. It also exposed the degrading oppression and abuse women received from the institutions they turned to for protection — the police, courts, religious institutions, medical providers, and their own families. The original domestic violence shelters and agencies focused on a woman’s autonomy and choice: “what does she want us to do and how can we best serve her?” The FJC movement has co-opted this focus with institutional collaboration, protocols, and financial incentives.
Early Sunday morning, Omar Mateen began killing people in what became the worst mass shooting in U.S. history. Authorities will now study what may have made the 29-year-old go to the Pulse gay nightclub with the intention of ending so many lives.
The Washington Post reported Monday that “although family members said Mateen had expressed anger about homosexuality, the shooter had no record of previous hate crimes.” But that depends on how you categorize domestic violence.
Mateen’s coworker, Daniel Gilroy, who requested a transfer so he wouldn’t have to work with Mateen, describes him as “scary in a concerning way…. He had anger management issues. Something would set him off, but the things that would set him off were always women, race or religion. [Those were] his button pushers.”
Mateen reportedly beat his ex-wife, Sitora Yusifiy, and at one point held her hostage, but was never held accountable. She divorced him after only four months of marriage, citing his mental-health issues. Her family, she says, had to “pull [her] out of his arms.” She describes Mateen as practicing his religion — Islam — but showing “no sign” of violent radicalism. It’s understandable what she means there, but perhaps it’s time our society started to think of physical abuse, possessiveness and men’s entitlement to act in those ways toward women as terroristic, violent and radical.
As Huffington Post reporter Melissa Jeltsen wrote last year, “The untold story of mass shootings in America is one of domestic violence.” According to a conservative estimate by the FBI, 57 percent of the mass shootings (involving more than four victims) between January 2009 and June 2014 involved a perpetrator killing an intimate partner or other family member. In other words, men killing women intimates and their children and relatives are the country’s prototypical mass shooters; these killings are horrifyingly common. In fact, on Sunday, while the world watched in horror as news poured out of Orlando, a man in New Mexico was arrested in the fatal shooting deaths of his wife and four daughters.
Even when intimate partners are not involved, gender and the dynamics of gender are salient. According to one detailed analysis, 64 percent of the victims of mass murders are women and children, and yet the role that masculinity and aggrieved male entitlement plays is largely sidelined. Schools, for example, make up 10 percent of the sites of mass shootings in the U.S., and women and girls are twice as likely to die in school shootings. Gyms, shopping malls and places of worship are also frequent targets, and are similarly places where women and girls are predictably present in greater numbers.
Homophobia is nothing if not grounded in profound misogyny. Regardless of religion or ethnicity, anti-LGTB rhetoric is the expression of dominant heterosexuality that feeds on toxic masculinity and rigid gender stereotypes. Sunday’s mass killing targeted the LGTBQ community — including people who violate gender rules, such as men who are “like women,” per Mateen’s thinking. What’s more, according to several Pulse regulars, Mateen had previously been to the nightclub a number of times, and investigators are also looking into whether he may have been using a gay dating app. It’s still unclear why he might have done those things, but at least a few people have said he may have been gay and closeted, potentially adding another dimension to his homophobia.
The club where the shooting took place, Pulse, had been known as a particularly a safe space for queer and trans people of color, groups who are the target of the fastest growing number of hate crimes in the United States. If Mateen’s choosing Pulse as a target isn’t an indication of aggrieved entitlement and fragile masculinity, I don’t know what is. Pledging allegiance to ISIS, as he is reported to have done in the midst of the shooting, while related in many dimensions to this problem, seems more like a symptom, not a cause.
Intimate partner violence and the toxic masculinity that fuels it are the canaries in the coal mine for understanding public terror, and yet this connection continues largely to be ignored, to everyone’s endangerment. It is essential to understand religious extremism (of all stripes), racism, homophobia, mental illness and gun use, but all of these factors are on ugly quotidian display in one place before all others: at home. If experts in countering violent extremism are looking for an obvious precursor to public massacres, this is where they should focus their attentions.
There are major problems to overcome before we’ll see real change, though. First, we need to fundamentally shift how we think about and assess “terror.” Just as the public’s consciousness has been raised in regards to race, ethnicity and the framing of only some agents of violence as “terrorists,” so too should we consider domestic violence a form of daily terror. Three women a day are killed by intimate partners in the United States, and the majority of women murdered are murdered by men they know. There needs to be a dissolution between what we think of as “domestic” violence, traditionally protected by patriarchal privacy norms and perpetrated by men against “their” women, and “public” violence, traditionally understood as male-on-male. Acts of public terrorism such as the one in Orlando Sunday would be less unpredictable if intimate partner violence were understood as a public health and safety issue, instead of as a private problem.
Second, we must address the reasons why many victims of domestic violence are not comfortable going to the police — for instance, the fact that sexual “misconduct” is the second most prevalent form of police misconduct, after excessive force. Additionally, high rates of police brutality, particularly in communities of color, constitute a form of terror. This fact should be inseparable from tolerance for high rates of intimate partner violence in police ranks. Women, and perhaps especially women of color, who might otherwise be able to alert law enforcement about the early signs of violence or radicalization do not currently feel safe or comfortable going to the police.
The third major issue to address is that of violent men and their access to guns. In households where an abusive spouse has access to a gun, women are five times more likely to be killed. And yet, men who violently abuse women they are related to are not barred from owning or buying guns if their domestic violence is never reported to the police or prosecuted. What’s more, gun-rights activists are trying to overturn a 1996 amendment to a federal law that says it’s illegal for a person who’s been convicted of a domestic violence misdemeanor to buy or own a gun. And currently people with restraining orders associated with intimate partner violence are only prohibited from owning or buying guns in fewer than half of U.S. states.
Fourth, it’s time to correlate the known risk factors for intimate partner killing, determined in what is known as a lethality assessment, to other factors that might help predict who will engage in acts of mass shooting and killing. Given the ridiculous pace of intimate partner and mass shootings, there’s no shortage of data to study. We know what behaviors presage men’s murdering women and children and then, often, turning guns on themselves. What if those metrics were integrated into models designed to understand and counter what is traditionally thought of as violence extremism? If, as Jelsten pointed out, experts believe that domestic homicides are “the most predictable and preventable of all homicides” then, given what we know about the inciting incidents in most mass shootings, so too are the majority of acts of public terror.
It does not take intensive analysis or complicated transnational databases to conclude that men who feel entitled to act violently, with impunity, against those they care for will, in all probability, feel greater entitlement to act violently toward those they hate or are scared of.
The sooner we start recognizing this fact, the safer not just women, but all of us, will become.
The man who committed the deadliest mass shooting by a lone gunman in U.S. history had a history of domestic violence and disrespecting women, according to people who were close to him. The emerging details about Omar Mateen fit into a bigger and often overlooked pattern of violence in this country, in which crimes against female partners often escalate to crimes against greater numbers of people.
Mateen, who opened fire at a gay nightclub in Orlando early Sunday morning — killing 49 people and wounding 53 others — used to abuse his wife.
“He was not a stable person,” Sitora Yusifiy, who was married to Mateen for about two years after the couple met on an online dating site, told the Washington Post. “He beat me. He would just come home and start beating me up because the laundry wasn’t finished or something like that.”
One of Mateen’s former coworkers, Daniel Gilroy, told the Miami Herald that Mateen often bragged about his relationships with other women while he was married to Yusifiy. “All he wanted to do was cheat on his wife,” Gilroy said. “He had very little respect for women.”
This news is unsurprising to people who work on issues related to domestic violence, sexual assault, and gender roles. There’s a lot of evidence that men who hurt their female family members often go on to hurt other people.
Between 2009 and 2012, 40 percent of mass shootings started with a shooter targeting his girlfriend, wife, or ex-wife.
Last year alone, nearly a third of mass shooting deaths were related in some way to domestic violence. And when you look beyond public shootings, the majority of mass shootings in this country actually take place inside the home, as men target the women and children they’re intimately related to.
Employing harassment, violence, and coercion against women has long been considered a normal way for men to behave in romantic relationships, as deeply ingrained gender norms teach men that they’re entitled to women’s bodies. This toxic approach to masculinity has been directly linked to the sense of entitlement that drives many mass shooters to commit their crimes.
Nonetheless, while national politicians are quick to pinpoint shooters’ crimes on their immigration status or religious affiliation, the harmful effect of toxic masculinity doesn’t receive the same high-profile attention.
Domestic violence advocates, however, say it’s obvious that men who commit crimes against women should be taken more seriously within society as a whole. As lawmakers debate the best way to prevent mass shootings, one policy solution would be tightening existing loopholes in an effort to make it more difficult for domestic abusers to obtain firearms.
Here are just a few recent examples of shootings where the perpetrators likely had a toxic attitude toward women before they opened fire — a list that includes many men who were directly connected to incidents of violence and abuse against women:
Mainak Sarkar, who made a kill list of his UCLA professors.
Earlier this month, the UCLA campus was shaken by the murder of a beloved professor in his office. Doctoral student Mainak Sarkar had planned to kill two of his former professors, but could only find one before he turned the gun on himself. Before Sarkar loaded up his backpack with guns and ammunition for the trip to UCLA, however, he murdered his estranged wife. According to authorities, he climbed through a window to kill her in her home.
Cedric Larry Ford, who killed 3 people in Hesston, Kansas.
Ford’s shooting spree in February at Excel Industries, which killed three of his co-workers, may have been prompted by receiving a restraining order from someone he had previously abused. He got the restraining order about 90 minutes before opening fire. Evidence from court documents shows that women in romantic relationships with Ford were afraid of him. One former girlfriend said that he tried to strangle her and that she was worried about his mental state.
John Russell Houser, who killed 2 people in Lafayette, Louisiana. Houser opened fire in a movie theater last July and, although his motive for the crime was unclear, his family had previously raised alarm about his violent behavior. In 2008, Houser’s wife asked for a temporary protective order against him, arguing that he “perpetrated various acts of family violence” and “has a history of mental health issues.” According to those court documents, his wife became so concerned that she removed all of the guns from the family home.
Robert Lewis Dear, who killed 3 people in Colorado Springs, Colorado. Dear, who opened fire in a Planned Parenthood clinic last fall, has a long history of being accused of preying on women. In 1997, authorities responded to a domestic violence call after Dear’s wife said he hit her and pushed her out of window. Five years later, he was investigated for making “unwanted advances” toward a neighbor, who said she was hiding in the bushes by her house and “leering” at her. She eventually filed a restraining order.
Syed Rizwan Farook, who killed 14 people in San Bernardino, California. There’s some evidence that Farook, who along with his wife Tashfeen Malik opened fire at a company holiday party last December, grew up in a violent home. In court documents regarding his parents’ divorce, Farook’s mother alleges his father abused her in front of the children — hitting her, pushing her toward a car, and once drunkenly dropping a TV on her. She sought multiple domestic violence protection orders against him. Witnessing this type of domestic violence in the home can have a serious impact on children who see a model for inappropriately treating women. Just days after the shooting, authorities investigated Farook’s brother on a possible charge of domestic battery.
Elliot Rodger, who killed 6 people in Santa Barbara, California. Rodger went on a rampage near a Santa Barbara, California university campus in 2014 against women who had romantically rejected him. In revenge for still being a virgin, which he perceived as women’s fault, he pledged to “slaughter every spoiled, stuck-up, blond slut I see” inside the “hottest sorority house of UCSB.” Rodger planned the crime for more than a year and was deeply involved with misogynistic online communities that have degrading attitudes toward women.
Cho Seung-Huim, who killed 32 people at Virginia Tech.
Before Cho committed one of the deadliest school shootings to date in 2007, two women complained that he was stalking them. They reported receiving persistent calls and messages from Cho, who went through campus disciplinary proceedings. After the massacre, Cho left behind a manifesto that the Associated Press described as a “rambling note raging against women,” as
The number of domestic violence-related deaths in Pima County increased by 50 percent between 2014 and 2015, according to the Arizona Coalition to End Sexual and Domestic Violence.
Ed Mercurio-Sakwa, the CEO of the local Emerge! Center Against Domestic Abuse, says that his organization’s hotline typically receives calls from about 5,500 individuals in Tucson each year.
Last year 5,900 called Emerge’s hotline, and Mercurio-Sakwa predicts that “this year we’re on pace for about 7,300 different calls,” an increase of more than 30 percent of the typical hotline traffic. “And the scary part of that is that’s just the tip of the iceberg,” Mercurio-Sakwa says.
“A lot of research shows that only about one in 10 incidents get reported,” Mercurio-Sakwa says, “The Tucson Police Department and Pima County Sheriff’s Department alone get almost 13,000 calls each year to 911 for domestic violence and again it’s probably about one-tenth of what’s really going on.”
Emerge! works with the Pima County Attorney’s office to provide victims with support and emergency resources through the Domestic Violence Court, established in 2007, but Mercurio-Sakwa admits that the Pima County legal system cannot provide justice for all victims.
One issue for victims, about 85 percent of whom are women, “is that the vast majority of domestic violence is emotional abuse, verbal abuse and economic abuse, which are not illegal, generally speaking,” Mercurio-Sakwa says.
The Domestic Violence Legal Empowerment and Appeals Project (DV LEAP), an organization out of Washington, D.C., that works to advance legal protections for victims and provide assistance during appeals processes nationwide, recognizes the shortcomings of protections against nonphysical forms of abuse.
“Even though there has been extensive training efforts to educate judges on the broader spectrum of behavior that encompasses domestic violence, judges rarely recognize or grant protection for controlling behavior that is the core of domestic violence,” says Sasha Drobnick, the legal director of DV LEAP.
These behaviors can include threats, intimidation, degradation, social isolation and financial manipulation, all with the goal of total control over the victim.
However, just because an abuser has not resorted to physical violence yet does not mean it won’t happen in the future.
“Somebody who is looking to control someone else will use whatever tactic necessary to gain that control,” Mercurio-Sakwa says, “That means that they will keep raising the level of abuse until they don’t have to anymore. So, abusers who feel like they can differentiate themselves from men who hit their wives are wrong. The truth is you’re not physical because you haven’t had to be, not because you wouldn’t be willing to.”
One of the overarching goals for DV LEAP is to develop “broader and more accurate definitions of domestic violence with domestic violence statutes that capture and provide protection against coercive control,” Drobnick says.
Even victims who suffer prosecutable forms of abuse face judicial shortcomings, an example of which is order of protection enforcement.
One option for victims of illegal abuse is an order of protection, which bars the perpetrator from any contact with the victim in person or any other way for one year.
Violations of orders of protection in Arizona are supposed to result in immediate arrest, possible jail time and fines.
Despite the order’s name, Mercurio-Sakwa says “it may just serve to piss (the abuser) off more, and at the end of the day it’s a piece of paper.”
One victim, who was granted her fourth order of protection against her husband and father of her children on March 4 in the Pima County Superior Court, asked presiding Judge Geoffrey Ferlan what she could do to keep her abuser from continuously violating the order of protection.
“Is there anything else I can do if I’ve already told the police and he’s still violating it?” she asked, sitting alone in front of the judge.
The victim said she reported all of the violations to the Tucson Police Department, but no actions were taken.
Ferlan could only respond with, “Legally, I can’t give you advice.”
The abuser, who previously served prison time for domestic violence, did not show up to a hearing that he requested to dispute the order of protection.
Court records describe incidents of stalking, choking, pushing and threatening the victim and their two children under the age of 10.
In one report, the victim wrote, “(the abuser) sent me a picture of a gun to his head saying he was going to kill myself, the kids, then himself.”
At the end of the brief hearing, after Ferlan recommended that the victim “continue to report the violations to the police and use resources like Emerge! to keep yourself safe,” she was escorted to her car by two court officers.
Unlike the legal system, which uniformly issues orders of protection and prosecutes domestic abusers, Emerge! focuses on individualized safety response plans.
“We feel like every situation is totally unique, and requires a customized response plan that may or may not involve the court,” Mercurio-Sakwa says.
Mercurio-Sakwa’s experience with victims taught him that not all victims want to prosecute or leave their abusers, whether for financial or familial reasons, and those that do want legal justice can face threats and intimidation in the process.
“Sometimes there is tremendous fear. The abuser will say, ‘I’m going to get out, they might arrest me but I’ll be out in a day or so,’” he says. “That’s real. That is a real safety risk for victims.”
Although victims can contact law enforcement if they feel threatened, a survey conducted by The National Domestic Violence Hotline in 2015 found that only one in five women nationwide who contacted the police about their abuse felt safer.
Intimidation outside of court can cause victims to recant or drop charges for their own safety.
One appeals case that DV LEAP is working on involves a domestic violence survivor who was denied a protective order because she previously dropped criminal charges against her abuser because of fear.
Recanting a statement or dropping charges can make a victim look unreliable, and make pressing subsequent charges or seeking protection more difficult.
“These behaviors are common among survivors and have many possible explanations, but the court chose to find that the abuse didn’t occur,” Drobnick says.
Although police departments nationwide are trained to protect victims from their abusers, in 2015 two-thirds of women suffering from domestic violence “were afraid the police would not believe them or do nothing,” according to The National Domestic Violence Hotline.
The Tucson Police Department did not respond to repeated requests for an interview about its experience with domestic violence incidents.
Although there were about 4,000 domestic violence-related deaths nationwide in 2015, the rate of domestic violence deaths in Pima County was 44 percent higher than the national rate.
Mercurio-Sakwa, a man working in a position traditionally occupied by women, feels that the next step in domestic violence prevention is “shifting the community conversation to the unhealthy aspects of masculinity.”
“We have for so long seen this as a women’s issue. It was left on their shoulders to somehow take care of it,” he says. “I find it really important that men hold each other accountable.”
Mercurio-Sakwa’s goals for the organization, while under his guidance, are to expand on prevention programs directed at men.
Although Emerge! is a positive place for victims to seek out the help they need, Mercurio-Sakwa was reluctant to admit, “unfortunately, we will never go out of business.”